OSHA Inspection: NATIONAL BEEF PACKING CO. LP

Issued

Dec 5, 1991

Abate by

Dec 16, 1991

Penalty

Initial $2,500 · Current $2,500

Issued

Dec 5, 1991

Abate by

Dec 16, 1991

Issued

Dec 5, 1991

Abate by

Dec 16, 1991

Issued

Dec 5, 1991

Abate by

Dec 10, 1992

Penalty

Initial $5,000 · Current $5,000

Issued

Dec 5, 1991

Abate by

Dec 10, 1992

Issued

Dec 5, 1991

Abate by

Dec 10, 1992

Issued

Dec 5, 1991

Abate by

Dec 10, 1992

Penalty

Initial $2,500 · Current $2,500

Issued

Dec 5, 1991

Abate by

Mar 10, 1993

Issued

Dec 5, 1991

Abate by

Dec 16, 1991

Issued

Dec 5, 1991

Abate by

Dec 10, 1992

Issued

Dec 5, 1991

Abate by

Jun 1, 1993

Penalty

Initial $5,000 · Current $5,000

Issued

Dec 5, 1991

Abate by

Dec 10, 1992

Penalty

Initial $5,000 · Current $5,000

Issued

Dec 5, 1991

Abate by

Dec 10, 1992

Issued

Dec 5, 1991

Abate by

Dec 10, 1992

Issued

Dec 5, 1991

Abate by

Dec 10, 1992

Issued

Dec 5, 1991

Abate by

Dec 10, 1992

Issued

Dec 5, 1991

Abate by

Dec 16, 1991

Issued

Dec 5, 1991

Abate by

Dec 10, 1992

Issued

Dec 5, 1991

Abate by

Dec 10, 1992

Issued

Dec 5, 1991

Abate by

Dec 10, 1992

Issued

Dec 5, 1991

Abate by

Dec 10, 1992

Issued

Dec 5, 1991

Abate by

Dec 10, 1992

Issued

Dec 5, 1991

Abate by

Dec 10, 1992

Issued

Dec 5, 1991

Abate by

Jan 7, 1992

Issued

Dec 5, 1991

Abate by

Dec 16, 1991

Issued

Dec 5, 1991

Abate by

Dec 16, 1992

Penalty

Initial $1,500 · Current $1,500

Issued

Dec 5, 1991

Abate by

Dec 16, 1991

Issued

Dec 5, 1991

Abate by

Dec 16, 1991

Issued

Dec 5, 1991

Abate by

Dec 16, 1991

Issued

Dec 5, 1991

Abate by

Jun 8, 1992

Penalty

Initial $5,000 · Current $5,000

Issued

Dec 5, 1991

Abate by

Jun 5, 1995

Penalty

Initial $50,000 · Current $30,000 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not furnish employment and a place of employment which
were free from recognized hazards that were causing or likely to cause
death or serious physical harm to employees in that employees were
required to perform tasks involving identified ergonomic risk factors
including but not limited to, repetitive motions, high force, and
awkward postures, resulting in stressors that had caused, were
causing, or were likely to cause cumulative trauma disorder(s):
(a) SCISSOR INTESTINES.  The evaluation of this task indicates that
employees are exposed to the Ergonomic hazards of arm flexion
(long reach), ulnar deviation of the wrist, wrist flexion, static
loading of scissor hand, static loading of scissor arm, high
repetition, and compression of scissor handles on the hand which
are causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to reduce
or eliminate such disorders.  The injury and illness records for
1989, 1990, and 1991 documented a pattern of cumulative trauma
disorders.
Examples of engineering controls applicable to this workplace include:
(i)  Adjust hooks
(ii)  New tool to pull intestine through to remove the waste
(iii)  Adjustable work height
(iv)  Change conveyor placement to eliminate reach during
placement of finished intestines.
(v)  Fixture to hold intestine
(vi)  Reorient work to pull/push in front of worker in the
horizontal plane
(b) REMOVE BRAIN.  The evaluation of this task indicates that
employees are exposed to the Ergonomic hazards of danger of being
hit by incoming heads,  arm abduction, torso flexion, heavy (4     0
lbs) lifting, precarious grasp, wrist extension, radial deviation
of the wrist, high finger forces, high repetition, and high arm
force which are causing or likely to cause cumulative trauma
disorders.  The employer did not implement an effective control
strategy to reduce or eliminate such disorders.  The injury and
illness records for 1989, 1990, and 1991 documented a pattern of
cumulative trauma disorders.
Examples of engineering controls applicable to this workplace
include:
(i)  Use a conveyor to bring heads to worker.
(ii)  Use a chute with less slope to slow heads and position them
close to the worker.
(iii)  Change height of end of chute so that heads could slide to
position instead of being lifted.
(iv)  Install a blade that slices open head and pries it open -
blade with mechanical assist.
(v)  Tool (ice cream scoop-like) for brains.
(iv)  Reposition the switches for the blade.
(vii)  Mechanically separate the halves of the skull.
(viii)  Maintain a sharp blade.
(ix)  Improve the blade attachment to keep it steady.
(x)  Use momentus or gravity to pull the brain free from its cavity
after splitting the skull.
(c) DROP HEADS.  The evaluation of this task indicates that employees
are exposed to the ergonomic hazards of lifting and carrying, high
force, high repetitions, wrist extension, wrist flexion, radial
deviation, and arm flexion which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement an
effective control strategy to reduce or eliminate such disorders.
The injury and illness records for 1989, 1990, and 1991 documented
a pattern of cumulative trauma disorders.
Examples of engineering controls applicable to this workplace include;
(i)  Have heads drop onto cleanable conveyor, (no lifting) then
flip head (if needed) and hook.
(ii)  Have conveyor beneath carcass conveyor for heads, attach
heads first and then cut from carcass.
(d)  SECOND BUTTER.  The evaluation of this task indicates that
employees are exposed to the Ergonomic hazards of higher finger
forces in a pinch type grasp, ulnar deviation, shoulder abduction,
high repetition, and trunk flexion which are causing or likely to
cause cumulative trauma disorders.  the employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  the injury and illness records for 1989, 1990, and 1991
documented a pattern of cumulative trauma disorders.
%%
Examples of engineering controls applicable to this workplace
include:
(i)  different shackles to correspond with carcass size.
(ii)  Change and maintain work height such that flexion is minimized
(iii)  Place a panel behind carcass to steady meat while cutting.
(iv)  Better grippers on the gloves.
(v)  Air-actuated clamps for the hide for the non-knife hand.
(vi)  Knife designed for primarily stab cuts.
(vii)  Monitor vibration and maintain tools.
(viii)  Study and individualize dubbing of the blades.
(e) SECOND LEGGER.  The evaluation of this task indicates that
employees are exposed to the Ergonomic hazards of wrist flexion,
wrist extension, radial deviation, high repetition, and trunk,
flexion which are causing or likely to cause cumulative trauma
disorders.  The employer did not implement an effective control
strategy to reduce or eliminate such disorders.  the injury and
illness records for 1989, 1990, and 1991 documented a pattern of
cumulative trauma disorders.
Examples of engineering controls applicable to this workplace
include:
(i)  Change and maintain work height such that back flexion is
minimized.
(ii)  Redesign knife for predominately stab 1 cuts with longer
handle possibly shorter blade.
(iii)  Eliminate flick of the wrist at the end of the cut near the
hock.
(f) WHIZZARD KNIFE - ROUGH MEAT.  The evaluation of this task
indicates that employees are exposed to the Ergonomic hazards of arm
flexion with shoulder abduction, wrist extension, wrist flexion,
ulnar deviation, forceful exertions, trunk flexion, trunk torsion,
extended reach, high repetition, vibration, and high grasp
force on the knife handle which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement an
effective control strategy to reduce or eliminate such disorders.
The injury and illness records for 1989. 1990, and 1991 documented
a pattern of cumulative trauma disorders.
Examples of engineering controls applicable to this workplace
include:
(i)  Provide an adjustable platform height so the worker can
control the height at which work is being performed.
(ii)  Redesign knife handle so that two a\hands may hold it.
(iii)  Slow the line pace.
(iv)  Position the carcasses to help in positioning.
(v)  Provide receptacle underneath the work area so that
strips may be allowed to fall.
(g)  TRIM INSIDE AND OUTSIDE SKIRTS.  The evaluation of this task
indicates  that employees are exposed to the ergonomic hazards of
arm extension with shoulder abduction while pulling and pushing,
long reach, ulnar deviation, radial deviation, wrist flexion,
trunk flexion, neck flexion, compression from the raised lip of
the work area, overhead throw, poor table height, and repetition
which are causing or likely to cause cumulative trauma disorders.
The employer did not implement an effective control strategy to
reduce or eliminate such disorders.  The injury and illness record
for 1989, 1990, and 1991 documented a pattern of cumulative trauma
disorders.
Examples of engineering controls applicable to this workplace
include:
i)  Remove or reduce the lip from worktable.
ii)  Reduce width of the work area.
iii)  Eliminate overhead throw.
iv)  Slow line pace.
v)  Provide an adjustable work table.
vi)  Use a mechanical skinning device to remove the fat from the
face of the meat.
vii)  Whizzard knife for face of meat.
viii)  Circular blade for side cuts.
%%
(h) NAVEL BONER. The evaluation of this task indicates that employees
are exposed to the Ergonomic hazards of arm extension with shoulder
abduction while pushing and pulling, long reach, trunk flexion,
heavy section of meat, ulnar deviation, radial deviation, wrist,
neck flexion, compression from the raised lip of the work area,
overhead throw, high repetition, and holding meat vertically which
are causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to reduce
or eliminate such disorders.  The injury and illness records for
1989, 1990, and 1991 document a pattern of cumulative trauma
disorders.
Examples of engineering controls applicable to this workplace
include:
i)  Eliminate overhead throw.
ii)  Provide a mechanical pull to remove connective tissue.
iii)  Provide a fixture for holding the meat vertically.
iv)  Change the work methods to eliminate extreme flexion.
v)  Provide for adjustable work table height.
vi)  Provide hook or clamp at far end of the meat to help hold it.
(i)  NAVEL BONES/CLEAN BONES/ROUGH MEAT.  The evaluation of this task
indicates that employees are exposed to the ergonomic hazards of
arm flexion with shoulder abduction, long reach, trunk flexion,
ulnar deviation, wrist flexion, high repetition, supination/
pronation with ulnar deviation, compression from the raised lip of the
work area, and an overhead throw which are causing or likely to
cause cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records for 1989, 1990, and 1991
documented a pattern of cumulative trauma disorders.
Examples of engineering controls applicable to this workplace
include:
i)  Reduce or remove the lip from the work area.
ii)  Reduce the width of the work table.
iii)  Eliminate the throw to the overhead conveyor.
iv)  Provide a mechanical device to "nibble" the sections from
the bones.
(j)  BONE RIBS.  The evaluation of this task indicates that employees
are exposed to the ergonomic hazards of arm flexion with shoulder
abduction while pulling, trunk flexion, long reach, high force
needed to pull layers apart, repetition,  overhead throw, ulnar
deviation, compression from the raised lip of the work ares, and
supination/pronation with ulnar deviation which are causing or
likely to cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or eliminate
such disorders.  The injury and illness records for 1989, 1990,
and 1991 documented a pattern of cumulative trauma disorders.
Examples of engineering controls applicable to this workplace
include:
i)  Remove or reduce the lip on the work table.
ii)  Provide a longer hook for reaching the meat.
iii)  Reduce the width of the work table.
iv)  Eliminate the throw to the overhead conveyor.
v)  Provide a fixture for holding the meat vertically.
vi)  Provide a mechanical fixture to help pull the layers apart.
vii)  Provide a gouging tool to help remove ribs.
(k) TRIM BRISKETS.  The evaluation of this task indicates that
employees are exposed to the ergonomic hazards of arm flexion with
shoulder abduction, long reach, trunk flexion, ulnar deviation,
radial deviation, wrist flexion, high repetition, and compression
from the raised lip of the work area which are causing or likely
to cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or eliminate
such disorders.  The injury and illness records for 1989, 1990,
and 1991 documented a pattern of cumulative trauma disorders.
Examples of engineering controls applicable to this workplace
include:
i)  Reduce or remove lip from work table.
ii)  Reduce the width of the work table.
iii)  Eliminate the throw to the overhead conveyor.
iv)  Provide a mechanical deice to "nibble" the sections of meat
from the bones.
(l)  CLOD PULLER.  The evaluation of this task indicates that
employees are exposed to the Ergonomic hazards of trunk flexion,
ulnar deviation, arm flexion with shoulder abduction, wrist
extension, wrist flexion, high repetition, and high force which are
causing or likely to cause cumulative trauma disorders.  The
employer did not implement an effective control strategy to reduce or
eliminate such disorders.  The injury and illness records for
1989, 1990 and 1991, documented a pattern of cumulative trauma
disorders.  Examples of engineering controls applicable to this
workplace include;
i) Redesign knife handle for stab position.
ii)  Conveyor system for workers to travel upon.
iii)  Bottom hook to help pull meat from the bone.
iv)  Stabilize the meat.
(m) DROP ROUND.  The evaluation of this task indicates that employees
are exposed to the Ergonomic hazards of radial deviation, wrist
extension, ulnar deviation, lateral back movement, back flexion,
shoulder abduction, shoulder flexion, compression of the hook
hand, high force, and high repetition which are causing or likely
to cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or eliminate
such disorders.  The injury and illness records for 1989, 1990,
and 1991 documented a pattern of cumulative trauma disorders.
Examples of engineering controls applicable to this workplace
include:
i)  Use an overhead conveyor system that adjusts the height of
the round ad the round goes down the line.  This will reduce
the need for the worker to raise his hands above his head
and/or bend over while dropping the round.
ii)  Hook the bottom portion of the round to a lower conveyor.
This will reduce the swinging motion of the round, therefore
reducing the need for the worker to steady the round.  In
addition the hook device conveyor can also be used to pull
the meat away from the bone.
iii)  Provide the workers with an ergonomically designed hook
that rests on the workers forearms.
iv)  Separate the cutting portion of this job from the part of
the job that separates the meat from the bone.  For example,
the first person would make the necessary cuts into the
round.  Once the cuts are made, a second person would hook
the hanging round to the lower conveyor that would pull the
round apart.
(n)  SEAM ROUNDS.  The evaluation of this task indicates that
employees are exposed to the ergonomic hazards of back flexion,
shoulder flexion, ulnar deviation, neck flexion, shoulder
abduction, lateral back movement, moderate to high force, high
repetition, and forceful shoulder exertion when using the forearm
to separate the round which are causing or likely to cause
cumulative trauma disorders.  The employer did not implement
an effective control strategy to reduce or eliminate such
disorders.  The injury and illness records from 1989, 1990, and
1991 documented a pattern of cumulative trauma disorders.
examples of engineering controls applicable to this work place
include:
i)  Use a longer hook to get the round.  This should reduce the
need to bend over the meat.
ii)  reduce the depth of the table.  This will reduce the need
for the long reach experienced by the worker when getting
and getting rid of the round.
iii)  Use mechanical device to assist in separating the round.
This should reduce the need for the worker to use his
forearm to separate the meat.
iv)  Eliminate or significantly reduce the lip on the edge of
the table.  This will help reduce the compression on the
workers body while seaming the round.  Furthermore, it will
allow the worker to pull the round closer to him by allowing
the meat to hang partially over the table during the seaming
process.
v)  Provide the workers with an ergonomically designed hook that
rests on the workers forearm.
vi)  Provide the workers with footrest.
(n) BONE HINDSHANKS.  The evaluation of this task indicates that
employees are exposed to the ergonomics hazards of shoulder
flexion, ulnar deviation, shoulder abduction, neck extension,
compression of the hook hand, moderate force,a nd high repetition
which are causing or likely to cause cumulative trauma disorders.
The employer did not implement an effective control strategy to
reduce or eliminate such disorders.  The injury and illness records
of 1989, 1990, and 1991 documented a pattern of cumulative
trauma disorders.
Examples of engineering controls applicable to this workplace
include;
i)  Extend the length of the walkway area.  This will allow the
workers more time to perform their job.
ii)  Provide an overhead conveyor that adjust the height of the
shank as the shank goes down the line.  this will reduce the
need for the workers to raise their hands and/or bend over
while cutting the hindshank.  Furthermore, with the extended
runway, the worker can begin working on the hindshank when
the shank is at the desired level and not have to worry
about running out of walkway area.
iii)  Hook the bottom portion of the hindshank to the lower
conveyor.  This will reduce the swinging motion of the
shank, therefore reducing the need for the worker to steady
the hindshank.  In addition, the hook conveyor device can
also be used to pull the meat away from the bone.
iv)  Provide the workers with an ergonomically designed hook that
rests on the worker's forearm.
v)  Separate the cutting portion of this job from the part of
the job that separates the meat from the bone.  For example,
the first person would make the necessary cuts into the
hindshank to the lower conveyor that would pull the meat off
the bone.
(p)  BONE BUTT.  The evaluation of this task indicates that employees
are exposed to the ergonomic hazards of shoulder abduction, neck
tilt, neck flexion, back flexion, ulnar deviation, used forearm
to separate the meat form the bone, elbow flexion, lateral back
extension, high force, and high repetition which are causing or
likely to cause cumulative trauma disorders.  The employer did not
implement an effective control strategy to reduce or eliminate
such disorders.  the injury and illness records for 1989, 1990,
and 1991 documented a pattern of cumulative trauma disorders.
Examples of engineering controls applicable to this workplace
include:
i)  Remove or significantly reduce the lip on the edge of the
work area.  This will reduce the compression on the workers
body.
ii)  Provide the worker with a longer hook to retrieve the butt
from the conveyor.  This will reduce the need for the worker
to reach so far.
iii)  Reduce the depth of the table.  This will also reduce the
need for the worker to reach so far to get the butt.
iv)  Eliminate the overhead bone toss.
v)  Provide the workers with a fixture and mechanical device
that can be sued to assist in separating the meat from the
bone.  This will eliminate the need for the worker to use
his forearm to help separate the meat form the bone.
vi)  Provide the workers with an ergonomically designed hook
that rests on the forearm.
vii)  Redesign the knife handle.
(q) BOX MEAT PACKAGE.  The evaluation of this task indicates that
employees are exposed to shoulder abduction, back flexion, long
reach, lateral back movement, shoulder extension, twisting of
lumbar, and shoulder flexion hazards which are causing or likely
to cause cumulative trauma disorders.  The injury and illness
records for 1989, 1990, and 1991 documented a pattern of
cumulative trauma disorders.
Examples of engineering controls applicable to this workplace
include;
i)  Provide the worker with an adjustable table that will allow
the worker to raise or lower the height of the table on
which the boxes that are being filled sit.  This will reduce
the need for the worker to bend over when filling the boxes.
ii)  Provide the worker with a device that pushes the filled
boxes to their desired location automatically.  This will
reduce the need for the workers to bend over and push the
heavy boxes away.
iii)  Provide the workers with a hoe type device that will allow
them to get the meat from the conveyor.  This will reduce
the need for the workers to reach so far over the conveyor
to get the meat.
iv)  Provide the worker  with a larger weight read out that is at
eye level.  Or have a scale that has a ringer or bell that
tells the worker which box (based on weight) that the cut of
meat should go into.  This will reduce the workers neck
flexion.
v)  Do not require the workers to run more than one line at a
time.
Among other methods, one feasible and acceptable abatement method to
correct this hazard is the implementation of an ergonomics management
program consisting of the following four elements.
(1)  WORKSITE ANALYSIS to recognize and identify existing ergonomic
risk factors in the workplace.  This analysis should include
development and use of ergonomic checklist and employee
questionnaire.  Periodic surveys of the workplace shall be
conducted at least annually to evaluate work practices and
engineering controls.  Employee participation in the ergonomic
program should be encouraged through a mechanism such as
a safety committee.
(2)  MEDICAL MANAGEMENT which includes accurate recordkeeping of
cumulative trauma disorders.  The program should address early
recognition, evaluation, and referral of cumulative trauma
disorder cases, and should include conservative treatment
conservative return to work.  Systematic worksite review by the
medical team should also be included in the program.
(3)  TRAINING AND EDUCATION for exposed employees, including methods
to evaluate the effectiveness of the training.  Re-training should
be done annually, or as operations change.  Training should
address hazards associated with the job, the risks of developing
cumulative trauma disorders, symptoms of exposure, and how to
prevent the occurrence of cumulative trauma disorders.  A
supervisors' training program should also be implemented to
allow recognition of the signs of cumulative trauma disorders
and to reinforce the employer's ergonomic program.
(4)  HAZARD PREVENTION AND CONTROL which includes engineering, work
practice and administrative controls, and personal protective
equipment where relevant.
(a) Engineering controls are designed by a qualified ergonomist
and may include workstation redesign, tool and handle
redesign, and change of work methods.  the goal of this program
should be to make the job fit the person.
Examples of engineering controls applicable to each cited
workplace are listed with the citation paragraph.
(b) Administrative controls are implemented which reduce the
duration, frequency, and severity of exposure to ergonomic
stress.  These controls may include job rotation, reduction
of repetitions, and preventive maintenance of related
equipment.  Personal protective equipment shall be
evaluated to determine and contribution to ergonomic stress.
(c) Work practice controls are implemented which include proper
work techniques, new employee conditioning, and monitoring
and modifications as necessary to minimize ergonomic stressors.
Step 1: Implementation of an ergonomic program for worksite analysis,
medical management, and training and education, as detailed
in items 1-3 above.
Step 2: Submit to the Area Director a written, detailed plan of
abatement outlining a schedule for the implementation of the
administrative, work practice, and engineering controls as
detailed in items 4(a) - 4(c).
%%
ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR EACH
PARTICULAR USE BY A PERSON TRAINED IN EVALUATION OF WORKPLACE
CONDITIONS WHICH CAUSE ERGONOMIC DISORDERS.  SIXTY (60) DAY
PROGRESS REPORTS ARE REQUIRED DURING THE ABATEMENT PERIOD.
Step 3: Implementation of administrative, work practice, and
engineering controls, as described in items 4(a) - 4(c).

Issued

Dec 5, 1991

Abate by

Jan 7, 1992

Penalty

Initial $50,000 · Current $30,000 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not furnish employment and a place of employment which
were free from recognized hazards that were causing or likely to cause
death or serious physical harm to employees in that employees who
sustained cumulative trauma disorder(s) (CTDs) were exposed to
increased risk of aggravation to existing injuries and illnesses and
developing further injuries and illnesses by inhibiting employees from
receiving adequate and timely medical care, by avoiding responsibility
of employee's CTDs or by not complying with physicians work
restrictions.
(a) At Slaughter and Fabrication operation that have resulted in
the development of CTDs, including at least 72 employees
that required surgery between 1-1-89 and 7-15-91.
(b) The employer failed to provide or inhibited employees from
medical care.  Instances include 20 employees that were
denied access by supervisors after report of CTD pain and
request for care.  Four (4) employees were denied time off
by supervisors to keep a scheduled appointment with a
physician for treatment of CTDs.   The on-site medical staff
inhibited, denied, or failed to refer 50 employees to
appropriate medical care when employees developed obvious
CTDs as evidenced by employees personal physician, and
requests by employees for appropriate medical care, even
when an employee had been sent to the "company
authorized physician" but was obviously and knowingly not
provided medical examination and treatment.  Of these instances
described, 18 employees required CTD surgery at a later time.
(The employees access to medical care was also deterred
by lack of communication between the non-english
speaking employees and medical personnel both on and off
site.)
(c) The employer attempted to avoid responsibility for
employee's CTDs thereby exposing employees to increased risk
of aggrevation to their existing illnesses.  There were 30
instances where either the employer or the company
authorized physician(s), who is an extension of the company's
medical management program, suggested that employees, with
CTDs, quit, resulting in employees seeking medical care at
their expense.  Nine (9) of these employees went on to have
CTD surgery,  (The lack of monitoring and tracking program
for employees with complaints or diagnoses of CTDs
contributed to avoidance of responsibility.)
(d) There were 30 instances in which employees, given a
physician's work restriction, were not put on work restriction
or were placed in work positions that did not fulfill the
the treating physician's idea of restricted duty.  Ten (10)
employees had surgery either before or after the restriction
was violated; permanent partial disabilities have resulted.
There was no concentrated effort on the part of management
or medical to determine that the restricted duty job was
lessening or worsening the employee's symptoms, and that
the restricted duty was maintained until the employee's
symptoms were resolved.
Among other methods, one feasible and acceptable abatement method to
correct this hazard is the implementation of an effective medical
management program for CTD's.
%%
General
%%
The medical management program is to be established under the guidance
of an appropriately qualified medical expert.  It will include:
1.  All employees visiting the plant medical facility to report
injuries or illnesses will be asked whether their medical condition
is caused or aggravated by work.  were the employee states that
the injury or illness id work-related, and that case otherwise
meets the criteria for recording, the case will be entered on the
OSHA log pending final determination of causation.
2.  Educate all employees, supervisors, and foremen on the early signs
and symptoms of CTDs and encourage the reporting of such signs and
symptoms to the medical department.
%%
The physicians providing medical services to the company's employees
need to be trained in the recognition, evaluation, and treatment of
CTDs.  Physicians providing medical services should show evidence of
having attended a course or seminar dealing with CTD's, such as a 2
or 3 day seminar at a minimum.  New employees will be given the
opportunity to condition their muscles and tendon groups prior to
working a full capacity (minimum 1 week).  In addition, a CTD
examination will be performed on all production employees 1 month after
assignment and annually thereafter.
%%
3.  The institution of a formal, documented tracking and surveillance
program to monitor CTD trends in the plant and those employees
having contracted a CTD to ensure adherence to the above
parameters.  This will also provide information about the
effectiveness of other aspects of the employer's program in
decreasing the number and severity of CTD cases.
4.  Employees shall not be discriminated against because they
reasonably request and visit the medical facilities or because they
have diagnosed CTD problems and are undergoing medical
rehabilitation.
5.  The institution of a formal job rotation program.
%%
Preventive Measures
%%
1.  Providing employees with early physician evaluation of CTD
symptoms.
2.  Allowing time off work for all muscle/tendon groups to heal after
a CTD is diagnosed.  The exact number of days off work is subject
to each worker's individual response and should be determined by
the physician.  A physician must sign off prior to an employee
being reassigned to job identified as posing high ergonomic
risk factors.
3.  The utilization of appropriate health care providers to develop
and implement conservative treatment measures upon detection of
CTD symptoms.  It is encouraged that several physicians be
available for employee referral and that employees be given the
opportunity to see the physician of their choosing.
%%
Treatment of CTD Cases
%%
1.  Health care providers assigning rehabilitation jobs will ensure
that the affected worker is assigned a job that will not further
exacerbate the injury or illness.
2.  After CTD surgery, allow time off work for all injured muscle/
tendon/nerve groups and the operative site to heal.  Again, the
exact number of days off work is subject to individual variation;
however, the following averages are provided:
After carpal tunnel release surgery and returning to
low ergonomic risk jobs             3 weeks off
medium ergonomic risk jobs          6 weeks off
high ergonomic risk jobs           12 weeks off
%%
After surgery for trigger finger and returning to
low ergonomic risk jobs             2 weeks off
medium ergonomic risk jobs          4 weeks off
high ergonomic risk jobs            6 weeks off
%%
However in no case shall employees be returned in less than:
%%
After carpal tunnel release surgery and returning to
low ergonomic risk jobs             8 days  off
medium ergonomic risk jobs         21 days  off
high ergonomic risk jobs           42 days  off
%%
After surgery for trigger finger and returning to
low ergonomic risk jobs             7 days  off
medium ergonomic risk jobs         14 days  off
high ergonomic risk jobs           42 days off
%%
Step 1: Implementation of an effective medical management program
for ergonomics, as detailed above.
%%